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10COV/DOCKKB? ROD
Surficial Soil*
Surficial soils at the site do not require remediation.
Subsurface Soil*
One potential need for remediation of subsurface soils is based on the ability
of a chemical to migrate (through leaching) and thereby impact ground water at
concentrations exceeding groundvater ARARS.
Only the vadose zone at the Upper Macon site (i.e., Lagoon 7) requires
remediation to mitigate the potential effects on ground water of volatile
organic compounds. Remediation of other vadose zone soils for groundwater is
not required, for the following reasons:
contaminant slugs have already passed through the vadose zone
further slugs of contamination have been eliminated by the removal of
the concentrated source areas during the interim remediation
conducted by the EPA
inorganic chemicals remaining in the vadose zone, although above
background levels, are not expected to adversely impact the ground
water; however, during remedial design, further evaluation of the
potential for impacting groundwater will be evaluated for but not
limited to chromium
organic chemicals remaining in the vadose zone are not expected to
adversely impact the ground water; however, during remedial design,
further evaluation of the potential for leaching at levels that
adversely impact groundwater will be evaluated
there is no direct exposure route from vadose zone chemicals to
humans or the environment
in the unlikely event that contaminants migrate from the vadose zone
to ground water above MCLS, they could be captured and removed from
the ground water by ground water extraction.
Material frc* Lagoon 10 at the Lower Macon site contains contains relatively
concentrated levels of PAHs in the waste. 'Lagoon 10 is covered by a temporary
cap that m* built during the initial site remediation in 1982-1983. since
this cap is temporary, there is the possibility that the cap could fail, thus
potentially exposing humans and the environment to impact from these wastes.
Consequently, Lagoon 10 requires remediation.
As discussed, the vadose zone at the upper Macon Site may adversely impact the
ground water (PCS at former Lagoon 7) while the vadose zone at the Lower Macon
site (i.e., Lagoon 10) may result in future exposure to the buried FAB
compounds. The estimated volume at Lagoon 7 that would require remediation is
1300 cubic yards. The estimated volume of remediation at Lagoon 10 is
88
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BOO
10Q.O cubic yards, wait* at Lagoon 10 is estimated to be from 2 to 10 feet
below the land surface.
surface
Surface water at the site does not require remediation.
Sediments
sediment at the site does not require remediation.
Vessels
A relevant and appropriate requirement for off-site disposal of vessel contents
is RCRA guidance. Additional characterization may be necessary depending on
the disposal alternatives that are considered.
89
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MACOH/DOOOKRY ROD
Tables 53 and 54 summarize the technologies considered for
remediating/controlling groundwater and source contamination, respectively at
the Macon/Dockery site. These tables also provide the rationale as to why
certain technologies were not retained for further consideration after the
initial screening, surface water/sediment remediation technologies were not
evaluated as this environmental medium has not been impacted by the Site nor is
it expected to be in the future. Although air is not a present exposure
pathway, it may pose a risk during the implementation of either the groundwater
treatment system or during the remediation of the soils. Any potential impact
on air will be considered along with the description of each individual
remedial alternative.
a. BKKKnTaT- *T.i»»»«%Tivga tp ADDRESS gaOOHDWATBR COMTAiiTHATIOM
The following alternatives were developed to address groundwater contamination
at the site. The three groundwater control (GWC) remedial alternatives are:
GHC-1A: NO Action
GWC-IB: Long-term Monitoring of Groundwater
GWC-2A: Recovery and Treatment of all site Groundwater exceeding
Groundwater Remediation'Levels using Air stripping,
coagulation/filtration
The remedial response actions to address groundwater contamination are
discussed below.
GWC-IA: Bo action
The NO Action alternative is included,-,as required by CERCLA and the NCP, to
serve as a baseline for comparison with other groundwater control measures.
This alternative would not involve any treatment or other remedial actions.
The description of this alternative is included in the following section.
GWC-lBt Soag-tsm Monitoring of Groundwater
This alternative is identical to GWC-IA but includes long-term monitoring of
site groundwater and the placement of deed restrictions to reduce the potential
for the construction of potable wells on the property.
In Alternatives GWC-IA and GWC-1B, site conditions would remain unchanged.
90
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TABLE 53
GROUND WATER CONTROL
TECHNOLOGY SUMMARY
EXTRACTION WELL
INTERCEPTION TRENCHES AND
SUBSURFACE DRAMS
NO ACTION
GROUND WATER TREATMENT
AIR STRIPPING
ACTIVATED CARBON ADSORPTION
SORPTTVE RESINS
CHEMICAL OXIDATION (UVOZONE)
BIOLOGICAL TREATMENT
LAND TREATMENT
PRECIPITATION
FILTRATION
REVERSE OSMOSIS
COAGULATION
GROUND WATER DISCHARGE
STATUS
RETAINED
REJECTED
RETAINED
RETAINED
RETAINED
REJECTED
RETAINED
REJECTED
REJECTED
REJECTED
RETAINED
REJECTED
RETAINED
SURFACE WATER RETAINED
HORIZONTAL INFILTRATION GALLERY RETAINED
INJECTION WELLS REJECTED
PUBUCLY OWNED TREATMENT WORKS (POTW) REJECTED
REASON
CANNOT BE INSTALLED AT DEPTH IN BEDROCK
EFFECTIVENESS AND RELIABILITY
CHLORINATED VOCS RESISTANTTO BIOOEGRADATTON
RESISTANT COMPOUNDS, SEASONAL USE
LIMITED EFFECTIVENESS
SUSCEPTIBLE TO CHEMICAL FOULING AND PLUGGING
PROVISIONALLY DEPENDING ON APPLICATION RATES
NOT PERMITTABLE
IMPLEMENTABUJTY
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TABLE 54
SOURCE CONTROL TECHNOLOGY SUMMARY
MACOIIOOCKERY
DIRECT TREA'
IN-SITU TREATMENT
OFF-SITE TREATMENT
CONTAINMENT
TECHNOLOGY STATUS
LAND TREATMENT RETAINED
MOAEACTOR REJECTED
8UPERCRmCAL CO2 EXTRACTION REJECTED
BEST PROCESS REJECTED
OXIDATION REJECTED
REDUCTION REJECTED
SUPERCRITICAL WATER OXIDATION REJECTED
SOIL WASHING REJECTED
CEMENTBASED STABILIZATION REJECTED
SILICATE-BASED STABILIZATION REJECTED
MODIFIED CLAY BASED STABILIZATION REJECTED
THERMOPLASTIC MICROENCAPSULATION REJECTED
TRANSPORTABLE INCINERATION REJECTED
LOW TEMPERATURE THERMAL SEPARATION REJECTED
SOIL VAPOR EXTRACTION RETAINED
ENHANCED BIODEGRADAT1ON REJECTED
SOIL FLUSHING REJECTED
VITRIFICATION REJECTED
COMMERCIAL LANDFILUNG RETAINED
COMMERCIAL INCINERATION RETAINED
CAPPING RETAINED
SLURRY WALL REJECTED
GROUTING REJECTED
SHEET PILING REJECTED
CONTAINER PILES REJECTED
ON-SfTE LANDFILL REJECTED
REASON
EFFECTIVENESS AND COSTS '•,'
NOT A DEMONSTRATED TECHNOLOGY
COSTS
LIMITED APPLICATION
NOT FULLY DEVELOPED
NOT DEMONSTRATED TECHNOLOGY
LIMITED FULL-SCALE APPLICATION
EFFECTIVENESS
EFFECTIVENESS
NOT DEMONSTRATED TECHNOLOGY
NO FIELD APPLICATION FOR SOILS
IMPLEMENTATION
IMPLEMENTATION
MORE EFFECTIVE TECHNOLOGY AVAILABLE
LIMITED EFFECTIVENESS
EFFECTIVENESS
IMPLEMENTATION
IMPLEMENTATION
IMPLEMENTATION
LIMITED FULL-SCALE APPLICATION
MORE EFFECTIVE TECHNOLOGY AVAILABLE
NO ACTION
RETAINED
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MACOW/DOCXKRI ROD
slight remediation of contaminated groundwater may occur through natural
process** such as biodegradation, adsorption, and attenuation by upgradient
flow. The low concentration of site-related chemicals.that would remain in the
ground water have the potential to discharge to Solomons creek.
implementation of Alternative GWC-IA could begin immediately and would have no
negative impacts of future remedial actions. Operating costs would be incurred
because of the mandatory review every five years, implementation of
Alternative GWC-18 may be delayed approximately one month as this approach may
include the installation of additional monitoring wells, in addition, under
GWC-IB, deed restrictions would be placed on the property in an attempt to
limit the future use of the groundwater. capital costs for GWC-13 would be
incurred for monitoring well construction; operating costs would include
periodic groundwater sampling, chemical analysis, and reviewing and documenting
site conditions every five years; maintenance costs would be incurred for
inspection of the monitoring wells.
Estimated period of operation: 30 years
Estimated Total Cost (net present worth):
Alternative GWC-1 $ 140,000
Alternative GWC-2 $1,840,000.
GHC-2A: Recovery and Treataent of all site Groundwater exceeding Groundwater
Remediation Levels using Air Stripping, Coagulation/Filtration
This alternative considers the entire Site as the point of compliance;
therefore, under this alternative all groundwater exceeding remediation levels
will be recovered through a system of extraction wells at the Upper Macon,
Lower Macon, Upper Dockery, and Lower Dockery sites as presented in Figures 8
and 9. The Site is delineated by the extent of contamination in the
groundwater.
The treatment systea for the extracted groundwater would involve installing
piping froa each extraction well to a common treatment area, a specific -
treatment system, and discharging the treated groundwater. Because of the
distance involved, separate treatment facilities will be specified for the
Macon and Dockery sites. The total extracted flow rate for Option GWC-2A is
estimated to be 40 gallons per minute (gpmy. The conceptual flow diagram for
ground water treataent is presented in Figure 10.
Air stripalB? is a mass transfer process in which volatile compounds in a water
column are transferred to an air stream within a packed tower. The air
stripping tower will remove the volatile compounds to below quantitation
limits. Under -north Carolina Air Pollution Rules* (ISA MCAC 2O.1104) a permit
is required for the emission of any toxic vocs. Toxic vocs should not be
emitted in such quantities that the resulting concentration at the property
line is above the allowable concentrations. Allowable concentrations of toxic
vocs are given in -North Carolina Air Pollution Rules- (ISA NCAC 2O.1104). To
satisfy North Carolina requirements, the impact of emissions from the proposed
air stripper for treating the contaminated ground water at the site was
93
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—vN*>
--=:-* \
rIOU« . - H.COH
-------
\ \
..&*#*'
Xefz
» - DOCIORT 8IW PROPOSED BKTRACTIOM MBU. LOCATION
I ' ' ' / ' I •
• ' / ' , ' I
/ !< //(••££
-------
ESTIMATED FLOW RATES
Macon Site 28 gpm
Dockery Site 12 gpm
Extraction
Wells
ConccntratkM
EqinltatkNi
Monitoring
Discharge to
Solomons Creek
or Infillration
Gallery
Air
Stripper
Coagulation/
Filtration
Note: • For purposes of the Feasibility Study, separate treatment facilities would be constructed for the Macon and
Dockery sites. Actual treatment requirements would be determined during Remedial Design. The actual
method of metals removed (if necessary) and discharge of treated groundwater would be determined
during Remedial Design.
Figure 10
Groundwater Treatment
Plow Diagram
Alternative (JWC-2A
-------
Macau/DOCX&KX
evaluated by utilizing the EPA SCREEN modal (EPA-450/2-78-027R). The results of
the air dispersion nodal conducted to estimate the airborne concentrations at
the property line found that the contaminant levels would be below allowable
state levels. Emission from proposed air strippers, therefore, will not
adversely impact the air quality of the site and its surroundings.
Filtration is a physical process in which metals are removed from groundwater
by forcing the fluid through a porous media. The metals are trapped or
enmeshed in the media. Filtration has been identified to be a successful
treatment technology for the removal of metals.
Coagulation is a phyBiochemical process used to agglomerate colloidal
suspensions and other small particulate matter that cannot be removed through
standard filtration, coagulation can generate significant volumes of sludge
that would require subsequent treatment and/or disposal. Commonly used
coagulants used for metals removal include lime, ferric sulfate, ferric
chloride and alum. Coagulation is an effective technology for the removal of
particulate metals.
Filtration would significantly remove metals. Coagulation would provide a
further level of treatment if filtration alone could not achieve the required
discharge levels for metals. Actual metals treatment requirements, if
necessary, will be established during Remedial Design.
Discharge of treated groundwater could be either to a surface water (Solomons
creek) or to an infiltration gallery, surface water discharge would require a
National Pollutant Discharge Elimination System (NPDES) permit, with an
infiltration gallery, the treated ground water is pumped into trenches lined
with gravel and allowed to percolate into the soil. A positive hydraulic head
is the driving force behind the system, as opposed to an active pumping system
injecting the water into the subsurface. The success of this method is
dependent on vadose zone acceptance of the treated water. An approved method
of percolation testing would be required to determine permissible application
rates of treated water. The infiltration gallery must be located so that
recharge to the aquifer does not interfere with the performance of the
extraction system. ,.
Estimated period of operation: 30 years
Estimated Total Cost (net present worth)s
Alternative GWC-2A $6,900,000
The response actions to address source control (SC) at the Macon/Dockery site
are:
sc-1: NO action
sc-2: Cap former Lagoon 7 and Lagoon 10
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MACOH/DOCXSKI ROD
SC-3t Soil vapor extraction (SVE) for Lagoon 7, cap Lagoon 10
sc-4t SVE for Lagoon 7, bioremediation for Lagoon 10
SC-St SVE for Lagoon 7, off-site disposal for Lagoon 10
Below are descriptions of each of the source control/remediation alternatives.
SO-ls Ho Action
Under the no action alternative, no further remedial activities would occur.
Subsurface soils underlying former Lagoon 7 would continue to act as a source
of chemicals to groundwater and the temporary cover over Lagoon 10 would remain
in place and unimproved. This no action alternative is required under the NCP
to serve as a baseline for comparison. A five year review of remedy would be
required.
The Mo Action alternative could be readily implemented, and would not hinder
any future remedial actions. There are no construction costs associated with
this alternative. However, operation and maintenance (O*M) costs would involve
review of the remedy every five years.
Estimated Period of Operation: 30 years
Total construction costs: $0
Estimated Present Worth otM Costs: $190.000
Estimated Total Costs (net present worth): $190,000
sc-2: Cap former Lagoon 7 and Lagoon 10
This alternative involves construction and operation of two low permeability
caps over Lagoon 7 and Lagoon 10, as shown in Figure 11 and 12. The areal
extent of the cap for Lagoon 7 and Lagoon 10 would be approximately 7,500
square feet and 13,000 square feet, respectively. The cap over Lagoon 7 would
address the potential for residual soil concentrations of PCS to impact ground
water above remediation levels. The existing cap over Lagoon 10 would be
replaced with a permanent design as a preventive maintenance measure to allow
better long-tern control of waste residuals.
capping is the covering of contaminated wastes or soils, in this approach, a
layer of compacted soil would be used to cover the area; this layer would be
covered with an impermeable synthetic liner to prevent wind, rain, and melting
snow from oasxying contaminants beyond their primary location. This approach
would alee prevent direct human and animal contact with contaminants. The
finished cap would be covered with soil and seeded for erosion control and to
make it blend into the landscape. Maintenance is minimal, requiring periodic
inspections and the filling of cracks or depressions, if they appear.
construction of a cap would involve heavy earth moving and grading equipment
and the clearing of vegetation. Existing site access would probably have to be
improved. Dust control measures would be taken to minimize short term
potential release of airborne particulates. In the implementation of this
98
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FQRMERiAioON;
PROPOSED CAP AT FOHMi
LAGOON 7
UPPER MACON SITE
-------
SOLOMONS CREEK
FIGURE 12
PROPOSED CAP AT LAGO<
LOWER MACON SITE
-------
HACOH/DOCXERT ROD
option, groundwater observation walls not required for long-tarn monitoring
would ba abandoned. Drainage awalas and a saeurity fanca would ba conatructad
along the cap perimeter. Deed restrictions would ba included in the
implementation of this alternative in order to control future use of the site.
There arc no ARARs for capping at the site, and Resource conservation and
Recovery Act (RCRA) disposal requirements are not applicable; however, the
single synthetic liner cap design would meet an equivalent standard of
performance to RCRA requirements.
Long-term effectiveness and permanence of this approach would rely on regular
inspections to ensure the reliability of the cap; an inspection and maintenance
schedule would be implemented following construction and continue as long as
chemical residuals remained at the Site. Evaluation of cap effectiveness would
be performed through periodic groundwater monitoring. If deemed necessary
during the design phase, gas vents will be incorporated into the cap. Because
residuals would remain at the site, CERCLA section 121(c) requires a review of
effectiveness and protectiveness be made every five years.
operating cost would be incurred to maintain the cap and to develop reports
and reviews of the Site remedy every five years. Biannual sampling would be
conducted under this alternative.
Estimated Period of Operation: 30 years
Estimated Total construction costs: ' $430,000
Estimated Present Worth O&M Costs: $260.000
Estimated Total Cost (net present worth)i $690,000
10
SC-3: soil vapor extraction (SVK) for Lagoon 7, cap Lagoon
This alternative involves the construction and operation of a replacement cap
over Lagoon 10 and a soil vapor extraction (SVE) system at former Lagoon 7.
capping is presented under Alternative sc-2. The analysis here will focus on
additional consideration* associated with application of SVB.
SVB would ba applied to former Lagoon 7 for the removal of tetrachloroethene
(PCE). Based on the v» modeling, PCS is the only compound in site soils with
the potential to causa ground water to exceed groundwater remediation levels.
Also based on the VIP modeling, target remediation levels for SVE at the site
would ba 3000 ug/kg PCS in the vadose zone'beneath former Lagoon 7.
SVE typioatUy includes a series of slotted vertical injection vents connected
by a COBBJOO manifold to an extraction pump or blower, volatile compounds and
some SVOC's are withdrawn through an induced pressure gradient in the
subsurface. Air emission* from the SVE system may require treatment, such as
being scrubbed or sent through an activated carbon filter, prior to being
vented to the atmosphere. The need for emission control would be determined
during the design, upon completion of SVE activities, there would no longer be
a significant source of chemicals to impact groundwater quality above the
identified ARARS. The effectiveness of SVB in thai removal of PCE from site
101
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MaCOH/DOCSERY ROD
soils would be evaluated through periodic sampling of the air emissions. Soil
borings would b« required to confirm that the tetrachloroethene remediation
levels had been achieved.
Estimated Period of operation: 1 year (SVE); 30 years (Cap)
Estimated Total Construction Costa: $630,000
Estimated Present worth otM costs» $370.000
Estimated Total Cost (net present worth): $1,000,000
SC-4: SVB for Lagoon 7, bioremediation for Lagoon 10
This alternative involves the operation of a SVE system at former Lagoon 7 and
biological treatment of Lagoon 10 wastes in a controlled cell. A description
of-the SVB system is presented in Alternative SC-3. Deed restrictions could
provide an added measure of safety by alerting potential property buyers of
residual contamination or by restricting usage of the property
Biological treatment would be applied to Lagoon 10 (Figure 11). Lagoon 10
contains various organic wastes, including 950 tons of creosote and solidified
sludge collected during EPA's immediate removal action.
Biodegradation of these compounds has been demonstrated under a variety of
environmental conditions and soil types. Previous studies have reported 80 to
90% removal of these compounds in less .than four months of treatment. This
technology is proposed in conjunction with SVE as an innovative alternative by
which Lagoon 10 wastes may be permanently destroyed. Installation of the SVE
system at Lagoon 7 may proceed concurrently with biological treatment of the
Lagoon 10 soils.
specific remedial objectives would be established after evaluation of a
treatability study. Treatment levels that could be achieved for the Lagoon 10
chemical residuals would be determined. As discussed, these residuals are not
expected to impact ground water. Any risks posed by the treatment residuals
would be through incidental human exposure. Risk assessment guidelines would
be used to establish protective levels of human health. Should the final
treatment levels be within the risk-based levels, the treated materials would
be replaced directly in the-lagoon. If the treatment levels exceed the
risk-based levels, a low permeability cap as described for Alternative sc-2
would be placed over the treated materials to deny incidental human exposure.
RCRA land disposal restrictions (LOR) are potential ARARs if the Lagoon 10
material* «z» determined to be a characteristic or listed hazardous waste.
Compounds' within Lagoon 10 are not among the characteristic waste compounds of
the Toxicity Characteristic Leaching procedure (TCLP; 55 FR 11798) that
establishes characteristic hazardous wastes. Lagoon 10 materials therefore
cannot be a characteristic waste. To be classified as listed hazardous waste
under RCRA, the following information must be ascertained: The exact
identification of the original waste stream, whether or not the material was
off-specification or past shelf life, and the material must contain a chemical
listed in 40 cnt 261.33 as the sole active ingredient. The information
102
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MtCOB/DOCXSRI ROD
collected thusfar in the RI/FS is insufficient to make these determinations,
and therefore the material in Lagoon 10 cannot be classified as listed
hazardous waste under RCRA. RCRA LDR are therefore not ARAR for the treatment
or disposal of Lagoon 10 materials.
Lagoon 10 wastes would be excavated and transferred to a lined waste treatment
cell where bioremediation would be conducted and monitored. The treatment cell
would be enclosed within a greenhouse-type structure that would serve to
maintain optimum microbial growth conditions and to control any air emissions.
Vapor phase carbon adsorption would be used, as necessary, to control emission
concentrations from the greenhouse. Treatment design and operation would be
established during Remedial Design.
Treated wastes would be returned to Lagoon 10 upon reaching the targeted
remediation level. The area containing the treated waste will be covered with
clean soil, graded, and revegetated. Actual closure requirements would be
established during Remedial Design.
Estimated Period of operation: 1 year (SVE); 25-31 months (Bioremediation)
Estimated Total Construction Costs: $1,300,000
Estimated Present Worth O4M costs: S 200.000
Estimated Total Cost (net present worth): $1,500,000
SC-5: SVB for Lagoon 7, off-cite disposal for Lagoon 10
This alternative involves the construction and operation of a soil vapor
extraction system at former Lagoon 7 and excavation of Lagoon 10 wastes for
disposal at a hazardous waste landfill. Detailed analysis of soil vapor
extraction at Lagoon 7 is presented in Alternative SC-3. off-site disposal of
Lagoon 10 wastes would significantly reduce the volume of waste materials and
provide a more comprehensive restoration of the site.
off-site landfilling of Lagoon 10 materials would have to conform to RCRA land
disposal restrictions (LDR; 40 cnt 268) if the materials were determined to be
hazardous. The materials in Lagoon 10 come from a number of unknown, disparate
sources that cannot be identified with any certainty. These materials would
therefore be classified as soil and debris potentially containing hazardous
waste under the LDR. SPA's office of solid and Hazardous waste has postponed
final standards for soils and debris until May of 1992. until then,
landfillinf of soils and debris would be based on whether the materials were
considers* huardous under TCLP analysis, should the materials exceed TCL?
regulatory levels, they would be disposed in a hazardous cell at a
RCRA-apprevsd facility. Otherwise, the Lagoon 10 soils could be placed in a
non-hazardous cell at the facility.
Removal of the waste materials would first involve removal of the synthetic
liner and the overlying clay cover. The waste materials would then be
excavated to native soils, a depth of approximately 10 feet. The volume of
waste materials is estimated to be approximately 1,000 cubic yards. Excavated
soils would be placed into lined roll-off boxes and then covered with a tarp.
103
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MACOeYDOCXSRY ROD
control'and ambient air monitoring would be conducted to minimize any air
emission impacts. Following removal of all waste materials, the excavation
would be backfilled with native soils and covered with compacted clay remaining
from the cap.
If the Lagoon 10 materials are hazardous, they would be manifested per RCRA
requirement* and hauled by a registered hazardous waste transporter. Trucks
would be washed down prior to leaving the site.
The actual disposal requirements and RCRA-approved facility would be determined
during Remedial Design.
Estimated Period of Operation: 1 year (SVE); 1 month (Disposal)
CLASSIFICATION
Hazardous Non-hazardous
Estimated Total construction Costs: $660,000 $410,000
Estimated Present Worth otM Costs: $110.000 $110.000
Estimated Total Cost (net present worth): $770,000 $520,000
t
S TO ADDRESS V8SS'lrr-g
There are 8 vats, 2 tankers, and 14 tanks at the Macon/Dockery site. The
contents of the site vessels are summarized in Table 55. Also on site is a
box trailer containing fertilizer and a boiler which may have asbestos
insulation. Following is a discussion of alternatives v-1 (no action) and v-2
(off -site disposal).
v-1: Ho Action
vessels would be left in place under this alternative, since the vessels and
their contents would not be addressed under this alternative, any potential
risks would remain. There would be no reduction in toxic ity or mobility of the
vessel contents. The volume of wastes in the vessels may fluctuate some
depending on rainwater influx and evaporation of oil and water. Periodic
inspection* would be required to evaluate containment of the vessel residuals.
A five-year review of this remedy would be required since waste materials would
remain at the »ite.
chemical pjsjj&sls within site vessels are contained and represent an
accidental exposure risk rather than an incidental exposure risk, vessels were
therefore net considered in the baseline risk assessments. The vessels
represent a potential safety hazard. This alternative would not eliminate
potential risk* from accidental spills of the vessel contents or from physical
injury from climbing on the vessels.
No action would pose no additional short term risks to the community or the
environment during implementation. However, as the integrity of the vessels
104
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ROD
degrade, the.-potential for the release of the contents of the vessels
ineraaaa. Ho action can ba implemented immediately.
There are no construction coats for this alternative. Operating coats would
consist of an annual inapection and review of remedy every five years.
Estimated Total Construction coats: 9 0
Estimated Present worth O&M costs: S90.000
Estimated Total Coat (net present worth): $90,000
V-2* Off-sit* diapoaal
Alternative V-2 would involve transferring all veaael contents into secure
transportation vehicles and dismantling the vessels, some or all of the
buildings may need to be demolished and removed during remediation of the
site. Hazardous veaael contents would be taken to a RCRA-approved facility for
disposal. Non-hazardous vessel contents and the vesael pieces would be
recycled or sent to an industrial landfill for disposal.
contents of the Site vessels are characterized in Table 38 and are summarized
in Table 55. Hazardous solids would be drummed and taken to a RCRA-approved
landfill for disposal while the remaining solids (including tar) would be
disposed as non-hazardous waste. Hater would be sent through the ground water
treatment system, or taken to the local Publicly Owned Treatment Works for
disposal, pending comparison with pretreatment requirements. Oil would be
pumped into tanker trucks for offsite reclamation or incineration, ultimate
disposition of the oils would be baaed on the bulk concentrations in the tanker
that would be sent to the receiving facility.
Fertilizer in the box trailer and the boiler insulation would be disposed of as
non-hazardous waste or recycled. Boiler insulation has not been characterized
but, based on the assumed age of construction, may contain asbestos.
characterization of the insulation would be required^ prior to dismantling the
boiler. To be conservative, it is assumed that disposal of boiler insulation
would have to comply with asbestos handling requirements.
Potential risk* fro* the vessels would be accidental and were not; .< addressed, in
the baseline risk asaessaents. This alternative would eliminate potential
risks from accidental spills of the vessel contents or from physical injury
froa climbing ea the vessels.
RCRA regulations ware identified as potentially relevant and appropriate ARARs
for vess«i resjsdiation. RCRA disposal guidance waa identified as an
action-specific ARAR while RCRA hazard characteristics were identified as a
chemical-specific ARAR (i.e., TCLP).
It is not known if the industrial boiler (Building 2, Figure 1) contains
friable asbestos. If this boiler does contain asbestos, three potential
action-specific ARARs may apply for offsite disposal: (1) 29 CFR parts
1910.1001 and 1926.58 (general asbestos regulations under the Occupational
105
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Tabto 35
SUMMARY OF VESSEL CONTENTS
VOLUME (Gallons)
HAZARDOUS* NON-HAZARDOUS TOTAL
Solids 100 500 600
Water 0 13,500 13,500
Oil 600 8,900 9,500
Tar 0 900 900
* Characterization as a hazardous waste is based on TCLP analysis. Lead was the only
constituent to exceed the TCLP regulatory level, in Vat 4, Tank 3 and Tank 4 (Table 3.10).
106
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nCOH/DOCXZBZ ROD
safety and Health Administration (OSHA) and construction/demolition
regulations, respectively), (2) North Carolina specifications for Asbestos
Abatement (Division of state Construction, Department of Administration, as
amended ia February 1988) and (3) 40 CFR Part 61 (CAA) EPA National Emission
Standard* for Hazardous Air pollutants (NESHAP). Most of these regulations
pertain to the packing and shipping of asbestos-containing materials such that
the amount of asbestos fibers entering the air and affecting potential human
exposure are minimized. Alternative v-2 would follow the OSHA, North Carolina
and EPA requirements and therefore would comply with these potential ARARS.
Since the vessels and their contents would be taken off-site and recycled or
disposed, there would be no residual risk following implementation of
Alternative V-2. since the tankers contain solids or tar that are not
hazardous according to RCRA toxicity characteristics, and would be difficult to
clean because of the tar and solids residues, off-site burial at an industrial
landfill (non-hazardous) would be feasible.
The volume and toxicity of materials at the Site would be permanently reduced
under this alternative. Incineration (hazardous materials) or recycling
(non-hazardous) would effect a permanent reduction in the absolute volume of
vessel contents.
vessel removal is estimated to take 2 months, short term risks involved in
this alternative would be from cutting to dismantle the vessels and in moving
the site vessels, other risks could resort from the removal of the solids from
Vat 4 because of the dust that could be generated, and from removal of the
boiler if it is found to contain friable asbestos. However, the low amount of
lead and the small volume of solids in vat 4 would minimize any effects from
the dust. Dust control and ambient air monitoring would be conducted to
minimize potential risks to the community. Potential worker exposure would be
reduced by using the appropriate personal protective equipment, as directed by
the remedial health and safety plan.
cleaning and removal of waste storage tanks has been successfully accomplished
at numerous hazardous waste sites and there are no special requirements at this
sit* that would lead to- implementation concerns. Transferring the vessel
contents and dismantling the vessels would be readily implemented.
If found to contain asbestos, the boiler would most likely be disposed in an
industrial waste cell at a municipal landfill. Asbestos is not considered a
hazardous waste.
Costs assmisjtsjd with Alternative v-2 would be direct and indirect construction
costs. Tfcssr* would be no operational costs.
Estimated Total Construction costs: $300,000
Estimated Present north out costs: $ 0
Estimated Total Cost (net present worth): $300,000
107
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1OCOH/DOCKBKT ROD
The three potential remedial alternatives to address groundwater control, five
potential remedial alternatives to address source control, and two alternatives
to address vessels were evaluated using the nine evaluation criteria as set
forth in the NCP 40 C.F.R. S 300.430 (e)<9). A brief description of each of
the nine evaluation criteria is provided below.
Threshold Criteria
1. overall Protection of Human Health and the Environment addresses how
an alternative as a whole will protect human health and the
environment. This includes an assessment of how the public health
and environment risks are properly eliminated, reduced, or controlled
through treatment, engineering controls, or controls placed on the
property to restrict access and (future) development. Deed
restriction* are examples of controls to restrict development.
(ARARsl addresses whether or not a remedy complies with all state and
federal environmental and public health laws and requirements that
apply or are relevant and appropriate to the conditions and cleanup
options at a specific site. If an ARAR cannot be met, the analysis
of the alternative must provide the grounds for invoicing a statutory
waiver.
Primary Balancing Criteria
3. Long-term Effectiveness and Permanence refers to the ability of an
alternative to maintain reliable protection of human health and the
environment over time once the cleanup goals have been met.
4. Reduction of Toxieitv. MobilityT or volume are the three principal
measures of the overall performance of an alternative. The 1986
amendments to the superfund statute emphasize that, whenever
possible, EPA should select a remedy that uses a treatment process to
permanently reduce the level of toxicity of contaminants at the site;
the spread of contaminants away from the source of contaminants; and
the volume, or amount, of contamination at the site.
5. thort-term Effectiveness refers to the likelihood of adverse impacts
oev human health or the environment that may be posed during the
construction and implementation of an alternative until cleanup goals
are) achieved.
6. Tfflrltrtntabilitv refers to the technical and administrative
feasibility of an alternative, including the availability of
materials and services needed to implement the alternative.
108
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ROD
' 7. coat includes the capital (up-front) cost of implementing an
alternative, as well as the cost of operating and maintaining the
alternative over the long term, and the net present worth of both the
capital and operation and maintenance costa.
Modifying Criteria
8. State Acceptance addresses whether, based on its review of the RI/FS
and Proposed Plan, the state concurs with, opposes, or has no
comments on the alternative EPA is proposing as the remedy for the
site.
9. Community Acceptance addresses whether the public concurs with EPA'a
Proposed Plan, community acceptance of this Proposed Plan will be
evaluated based on comments received at the public meetings and
during the public comment period.
These evaluation criteria relate directly to requirements in section 121 of
CERCLA, 42 O.S.C. section 9621, which determine the overall feasibility and
acceptability of the remedy. Threshold criteria must be satisfied in order for
a remedy to be eligible for selection. Primary balancing criteria are used to
weigh major trade-offs between remedies. State and community acceptance are
modifying criteria formally taken into account after public comment is received
on the Proposed Plan. The evaluation of the three potential remedial
alternatives to address groundwater control, five potential remedial
alternatives to address source control, and two alternatives to address vessels
were developed as follows (Table 56). -
The following alternatives were subjected to detailed analysis for migration
control:
GWC-lAt Ho Action
owe-IB» Long-term Monitoring of Groundwater
GWC-2At Recovery and Treatment of all Site Groundwater exceeding
Oroundvater Remediation Levels using Air stripping,
coagulation/filtration
overall FMteotion of flMffflfl Health and the environment
The no action and long-term monitoring of groundwater alternatives would be
protective of human health and the environment under current condition, in the
future, ground water migration will not pose a risk to the environment, but
could pose a risk to human health if a potable well were to be installed at the
site, currently there are no ground water receptors at the site or immediately
downgradient of the property, and future receptors are unlikely, consequently,
the risk estimate for the site is an estimate of potential future risk of human
health.
109
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TABLE s«
TOTAL PRESENT WORTH COSTS FOR
RETAINED REMEDIAL ALTERNATIVES
Ground Water Control
GWC-1A
GWC-1B
GWC-2A
Source Control
SC-1
SC-2
SC-3
SC-4
SC-5
V-1
V-2
MACON/DOCKERY SITE
Corrective Action
No action
Long-term monitoring
of ground water
Ground water extraction
for MCLs across Site, air
stripping, coagulation/
filtration
No action
Cap former Lagoon 7 and
Lagoon 10
Soil vapor extraction for
former Lagoon 7, cap
Lagoon 10
Total Present
Worth Costs
$140,000
$1,800,000
$6,900,000 (X year duration)
Sofl vapor extraction for
former Lagoon 7, off-site
landflfling for Lagoon 10
No action
Off-site disposal
$190,000
$690,000
$1,100,000
Soil vapor extraction for $1,500,000
former Lagoon 7, bioremediate
Lagoon 10
$770,000 (hazardous)
$520,000 (non-hazardous)
$90,000
$300,000
110
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KaCOB/DOCXXRT ROD
Alternative CWC-2A would be protective of human health and the environment, now
and in the future, since this treatment alternative would result in MCLS being
achieved at all times at potential exposure points.
compli«pge, with
Concentrations of VOCs in ground water located beneath the site exceed
groundwater remediation levels, consequently the no action alternative (GWC-1A)
and long-term monitoring of groundwater GWC-1B) would not satisfy ARARs across
the site. Ground water extraction alternative GWC-2A would satisfy ground
water ARARs. construction of the ground water extraction, treatment, and
discharge system for Alternative GHC-2A would satisfy action-specific ARARs.
Liono— term Effectiveness and Permanence
Alternative GWC-2A would permanently reduce the magnitude of potential risks
at the site through future exposure to groundwater. Well point extraction of
ground water and air stripping are demonstrated technologies that can be
readily inspected and repaired, if necessary. Air stripping can readily
achieve the concentrations necessary for discharge to Solomons creek. Periodic
samplings of the treated effluent would be required.
Reduction of Toxic itv. Mobility or volume
The no action and long-term monitoring of groundwater alternatives would not
significantly reduce the toxicity, mobility or volume of contaminants in ground
water. Alternative GWC-2A would permanently reduce the mass of voca in ground
water .
short-term Effectiveness
None of the alternatives would pose a risk to the community or remedial workers
through implementation. Construction schedules for the alternatives would be:
Alternative GKC-1A: none
Alternative GNC-lBt 1 month
Alternative GWC-2A« 4 months
Implementation of Alternative CWC-2A would require approximately 30 years.
None of tbs> alternatives would pose any significant difficulties regarding
construction or operation. Design of any treatment system could not be
completed until discharge requirements were defined.
cost
Total present worth costs for the ground water control alternatives are
presented below t
111
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IttCOBT/DOCXBRY ROD
Alternative GWC-1A: $ 140,000
Alternative GWC-IB: $1,840,000
Alternative GWC-2A: $6,900,000 (30 year duration.)
b.
The following alternatives were developed for Site soils and were subjected to
detailed analysis:
SC-1: Ho action
SC-2: Cap former Lagoon 7 and Lagoon 10
SC-3: Soil vapor extraction (SVE) for Lagoon 7, cap Lagoon 10
SC-4: SVE for Lagoon 7, bioremediation for Lagoon 10
SC-5j SVE for Lagoon 7, off-site disposal for Lagoon 10
A summary of the evaluation of these alternatives is presented below.
Overall Protection of Human Health and the Environment
The no action alternative is not protective of human health and the environment
and does not assure the attainment of ARARs. Capping (Alternative SC-2) and
SVE (Alternatives SC-3, 4, and 5) would reduce chemical loadings to ground
water from Lagoon 7 and thereby lessen any risks to potential downgradient
receptors in the future. Long term containment or remediation of Lagoon 10
will be necessary to control any potential future risk posed by these wastes.
compliance with ARARs
The only identified ARAR for site surficial soils are the proposed RCRA
corrective action levels. The only surficial soil compound posing potential
risk* is arsenic, whose maximum concentration was significantly less than the
RCRA action level. Concentrations at the site and therefore each of the source
control alternatives, satisfy the RCRA action level.
soils at Lagoon 7 have caused vocs in groundwater to exceed groundvater
remediation levels. Capping and SVE would'significantly reduce further
leaching oC contaminants to ground water from Lagoon 7. The cap in
Alternatives) *c-2 and 3 would be designed to comply with RCRA performance
standard*. The SVE system in Alternatives SC-3, 4, and 5 would be operated in
accordance with North Carolina air emission requirements, off-site disposal
(e.g., landfilling) of soils would comply with EPA's off-site policy and land
disposal restriction* (Alternative sc-5).
Long-term Effectiveness and Perm«nence
Based on the VIP model, PCS is the only compound found in site soils with the
112
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MaCOBJ/DOCKSRY ROD
potential to-'impact groundwatar above remediation levels. The migration of PCX
to groundmter from Lagoon 7 would be permanently controlled by capping and
SVZ. The net reduction in chemical residual through bioremediation
(Alternative SC-4) would require a treatability study.
Reduction of Toxleitv. Mobility or volume
The no action alternative would not significantly reduce the toxicity, mobility
or volume of remaining site residuals, capping would significantly reduce the
mobility of site residuals. SVZ would significantly reduce the volume of site
residual! that could impact groundvater above remediation levels.
Bioremediation would effect a permanent but undetermined reduction in the
volume of chemical residuals in Lagoon 10. The volume of chemical residuals at
the site would be significantly reduced through off-site landfilling of Lagoon
10 waste materials.
short-term Effectiveness
None of the alternatives would pose a risk to the community or remedial worker
through implementation. Construction and operation schedules for the
alternatives would be:
Alternative SC-1: 0 months
Alternative sc-2: 3 months
Alternative SC-3« 6-12 months
Alternative SC-4: 25-31 months
Alternative SC-5: 2 months
Imolementabilitv
Hone of the alternative would pose any significant construction nor operational
difficulties, although periodic inspections and repair of the cap(s) would be
required. Actual implementation requirements for bioremediation would be
established through treatability testing.
cost
Total present worth costs for the source control alternatives are presented
belowt
Alternative sols $ 190,000
Alternative sc-2« $ 690,ooo
Altanative 8C-3i $1,100,000
Alternative sc-4s $1,500,000
Alternative SC-5i $ 770,000 (hazardous)
$ 520,000 (non-hazardous)
113
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BOO
C. .
Two alternatives were considered for Site vessels:
V-lj No action
V-2: Off-site disposal
The vessel alternatives are compared below.
Overall Protection of Human Heath and the Environment
Alternative v-1 would not eliminate potential risks from accidental spills of
the vessel contents or from physical injury from climbing on the vessels
whereas Alternative V-2 would.
Compliance with ARARs
RCRA regulations were identified as potentially relevant and appropriate ARARs
for off-site disposal of vessel contents. This action-specific ARAR for
off-site disposal, however, is not an ARAR under the no action alternative.
Consequently, this alternative would not violate any identified ARARS.
Alternative V-2 would follow appropriate RCRA, OSHA, KESHAP, and North Carolina
requirements and therefore would comply with these potential ARARS.
Long-tarn Effectiveness and Permanence •
since the vessels and their contents would not be addressed under alternative
v-1, any potential risks would remain. Periodic inspections would be required
to evaluate containment of the vessel residuals. A five-year review of remedy
would be required since waste materials would remain at the Site.
since the vessels and their contents would be taken off-site and recycled or
disposed (with the possible exception of the tankers), there would be no
residual risk following implementation of Alternative V-2. Since the tankers
contain solid* or tar that are not hazardous according to RCRA toxicity
characteristics, and would be difficult to clean because of the tar and solids
residues, off-site burial at an industrial landfill (non-hazardous) would be
feasible.
Reduction *** 9axi.ei.tv. Mohilitv and Voliim*
There woaleTse* no reduction in toxicity or mobility of the vessel contents
under alternative v-1. The volume of wastes in the vessels may fluctuate tome
depending on rainwater influx and evaporation of oil and water.
The volume and toxicity of materials at the site would be permanently reduced
under alternative V-2. incineration (hazardous materials) or recycling
(non-hazardous) would effect a permanent reduction in the absolute volume of
vessel contents.
114
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Shor<-term
No action would not eliminate potential risks to the conmunity or the
environment daring implementation. Ho action can be implemented immediately.
vessel removal is estimated to take 2 months. Short term risks involved in
this alternative would be from cutting to dismantle the vessels and in moving
the Site vessels, other risks could result from the removal of the solids from
Vat 4 because of the dust that could be generated, and from removal of the
boiler if it is found to contain friable asbestos. However, the low amount of
lead and the small volume of solids in vat 4 would minimize any effects from
the dust. Dust control and ambient air monitoring would be conducted to
minimize potential risks to the community, potential worker exposure would be
reduced by using the appropriate personal protective equipment, as directed by
the remedial health and safety plan.
Implementabilitv
Consideration of implementability is not applicable since the vessels would not
be addressed under the no action alternative (V-l),
Cleaning and removal of waste storage tanks has been successfully accomplished
at numerous hazardous waste sites and there are no special requirements at this
Site that would lead to implementation concerns. There are a number of
qualified companies that specialize in this type of remedial work.
Transferring the vessel contents and dismantling the vessels would be readily
implemented.
cost
Total present worth costs for the vessel alternatives are presented below:
Alternative v-lt $ 90,000
Alternative v-2: $ 300,000
d.
state and coanunity acceptance are modifying criteria, that shall be considered
in selecting the remedial action.
state
The State) «f North Carolina concurs with the selected remedy.
A Proposed Plan Fact sheet was released to the public on July 25, 1991. The
Proposed Plan public meeting was held on August 6, 1991.
The public comment period on the Proposed Plan was to be held from July 25,
1991, to August 23, 1991. The public comment period was extended an additional
115
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30 days in response to a request for an extension dated August 19, 1991
received froa the PRPs. Due to the letter from the PRPs requesting an
extension, the public comment period did not end until September 23, 1991.
Two letters and one set of written comments were received during the public
comment period. These letters, comments, and questions asked during the August
6 public meeting are summarized in the attached Responsiveness summary.
116
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MeCOH/DOOOSRI ROD
Section 121 of CERCLA, as amended, 42 U.S.C. 5 9621, and the National Oil and
Hazardous Substance pollution Contingency Plan (NCP) establish a variety of
requirements relating to the selection of the remedial action under CERCLA.
Having applied the evaluation criteria to the three potential remedial
alternatives to address groundvater control, five potential remedial
alternatives to address source control, and two alternatives to address
vessels, EPA has selected the following remedy for the Hacon/Dockery site.
Ground Water Control
GWC-2A Recovery and Treatment of all site Groundvater exceeding
Groundvater Remediation Levels using Air stripping,
coagulation/filtration
source control
SC-4 soil vapor extraction (SVE) for Lagoon 7, bioremediation for
Lagoon 10
Vessels
V-2 Off-ait*- disposal
A description of the selected remedies can be found in Section 8 of the ROD.
TRRATMEHT. AHD DISCHARGE
This remedial action vill consist of a groundvater extraction and treatment
system, and an overall monitoring program for the Site. Groundvater
contaminated above the remediation levels indicated in Table 57 vill be
extracted across the entire Site. This vill be accomplished by installing a
series of extraction wells located within and at the periphery of the
contaminant plume in the aquifer.
The estimated total volumetric flov is 57,600 gallons per day. This is based
on a 40 gpa> groundvater extraction system operating 24 hours a day. More
precise gxoondvater vithdraval and discharge values vill be developed as part
of the rsaadisl design. As stated previously, the point of compliance is the
entire Slte>.
The extraction system vill be developed in the remedial design, it is
anticipated that 12 extraction veils vill be needed (refer to Figure 8 and 9).
Additional monitoring veils, pump tests and groundvater modeling may be
required for the design of the extraction system.
117
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luUlu 57 tiiuund- Wului lluiiHiillitllon (.uvula l:oi Iliu Mauun/Uuuluiiy Ulle
do
T>
08
1
u
V
V
V
V
V
V
V
V
V
V
V
V
V
Cliuinluiil
Antimony
Doiluin
Betyllluiii
Cadmium
Chromium
.onU
Manganese <
Mercury
Nllohol
Vanadium
Zlno
[2 vanlUo
Isophoroiio
Aoelone
Benzuiio
Chloroloriu
1,1 -Dlcliloioullmuu
1,1 -Dlchloiuulliaiiu ,
1,2-Dlclitoroolliuno (lolal)
Molhylone Chloildu
Telrocliloroolliuno
Toluene
1,1,1-TilolilorouJluuiu
trJchloroelliene
Vinyl Chloride
Xylenes (Total)
MllKllllUIII
Cone.
(UU/L)
uu
G7IU
22
G
HUU
7U
utau
0.3
2120
U27
730
10.4
2
GO
0
17
1UO
CIO
150
2
44
7
500
2UO
510
9
Well
lumber
1U
0
G
1C
5
0
G
15
U
C
0
1 10
0,10
20
ID
1
U.I'J
15
5
2A
5
« '
15
2
9
19
Remediation
/Level
'(UQ/L)
60
1000 (1)
1
6
60
15
50(3)
1.1
100 (2)
60
5000 13)
164
70
3600
1
.19
3500
7
cls-70;lran»-70
5(2)
0.7
1000
200
2.6
0.015
400
Source
CERCLA Detection Limit
8DWA MCL/NC Ground Water Standard
SDWA MCL
NO Ground Water Standard
NC Ground Water Standard
CEHCLA Level
SDWA MCL/NC Ground Water Standard
NC Ground Water Standard
SDWA MCL
CERCLA Detection Limit
SDWA MCL/NC Ground Water Standard
NC Ground Water Standard
Preliminary Pollutant Limit Value (PPLV)
Preliminary Pollutant Limit Value (PPLV)
NC Ground Water Standard
NC Ground Water Standard
Preliminary Pollutant Limit Value (PPLV)
SDWA MCL/NC Ground Water Standard
NC Ground Water Standard
SDWA MCL/NC Ground Water Standard
NC Ground Water Standard
SDWA MCL/NC Ground Water Standard
SDWA MCL/NC Ground Water Standard
NC Ground Water Standard
NC Ground Water Standard
NC Ground Water Standard
CERCLA Detection Until - Conbacl Required Detection Uiult (Inorganics)
CERCLA QuanllUUon Limit - Contract Required Quantltallon Limit (organlcs)
SDWA MC.L - Sale Diluklng Water Act Maximum Contaminant Level (40 CFR Part 141.61)
North Carolina Ground Water Standard* lor ground water class QA Irom NCAC Title 16A. Ch.2, Oct. 1000
Preliminary Pollutant Limit Value (PPLV) derived In Appendix D ol Hie PS
(1) • Proposed revised MCL lor boilum Is 2UOO uy/L
(2) - Proposed MCL (pMCL)
(3) - Secondary (aesthetic) stunduid
I - Inorganic;U - BaseExiiucluula Oigunlo Compound; V ~ Volatile Organic Compound
-------
mCOBT/DOOKKRY ROD
Treatment of"groundwater will be accomplished by means of an air stripping
tower. From the extraction wells, groundwater will be pumped into an
equalization tank before it is fed to the air stripping system. The air
stripper will remove the VOCs from the groundwater. Discharge of treated
groundwater will be either to a surface water (Solomons Creek) or to an
infiltration gallery. If the treated groundwater meets standards to be
specified in the MPOBS discharge permit, it will be discharged to Solomons
Creek. On-site discharge to an infiltration gallery would have to comply with
the substantive requirements of a Non-Discharge Permit (ISA NCAC 2H.0200) as
administered by the state of North Carolina. Due to the potential of having
concentrations of metals above allowable levels in the effluent under the NPDES
program, it may be necessary to reduce metal concentrations in the groundvater
prior to discharge. Metal removal from the groundwater may consist of
filtration/coagulation or some other coat effective method.
The following details will need to be addressed as part of the remedial design:
(1) the need to remove metals from the extracted groundwater prior to
discharging to Solomons creek or an infiltration gallery; (2) the disposal of
any waste stream associated with the removal of metals; and (3) the need for
controlling the off-gas of the air stripper. The necessity for removing metals
prior to discharging the treated groundwater to Solomons Creek or an on-site
infiltration gallery will be addressed in the preparation for obtaining the
NPDES discharge permit or Non-Discharge Permit. Data generated as part of the
RD will also confirm if the off-gas from the air stripper, laden with volatiles
stripped from the groundwater, will need to be controlled.
As stated previously, the goal of this -remedial action is to restore
groundwater to its beneficial use as a drinking water source. Based on
information obtained during the RI and on a careful analysis of all remedial
alternatives, EPA and the State of North Carolina believe that the selected
remedy will achieve this goal. Groundwater contamination may be especially
persistent in the immediate vicinity of the contaminants' source, where
concentrations are relatively high. The ability to achieve cleanup goals at
all points throughout the area of the plume, cannot be determined until the
extraction system has been implemented, modified as necessary, and plume
response monitored over tine. Xf the implemented groundwater extraction system
cannot meet the specified remediation goals, at any or all of the monitoring
points daring implementation, the contingency measures and goals described
below may replace the selected remedy and goals for these portions of the
plum*. Such contingency measures will, at a "»t"^"VT?') prevent further migration
of the plusjsj and include a combination of containment technologies and
institutional controls. These measures are considered to be protective of
human health- and the environment and are technically practicable under the
correspoadiag- circumstances.
The selected remedy will include groundwater extraction for an estimated period
of 30 years, during which time the system's performance will be carefully
monitored on a regular basis and adjusted as warranted by the performance data
collected during operation. Modifications may include any or all of the
followingi
alternating pumping at wells to eliminate stagnation points;
119
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JUCUH/DOCXERT ROD
. - pulse pumping to allow aquifer equilibration and to allow adsorbed
contaminant* to partition into groundwater;
installation of additional extraction wells to facilitate or
accelerate cleanup of the contaminant plume; and
at individual wells where cleanup goals have been attained, and after
analytical confirmation, pumping may be discontinued.
To ensure that cleanup goals will be obtained and maintained, the aquifer will
be monitored at those wells where pumping has ceased initially every year
following discontinuation of groundwater extraction. This monitoring will be
incorporated into an overall site monitoring program which will be fully
delineated in the operations and Maintenance portion of the Remedial Design.
If it is determined, on the basis of the preceding criteria and the system
performance data, that certain portions of the aquifer cannot be restored to
their beneficial use, all of the following measures involving long-term
management may occur, for an indefinite period of time, as- a modification of
the existing system:
engineering controls such as physical barriers, or long-term gradient
control provided by low level pumping, as containment measures;
chemcial-specific ARARs may be waived for the cleanup of those
portions of the aquifer based on the technical impracticability of
achieving further containment reduction;
institutional controls may be provided/maintained to restrict access
to those portions of the aquifer which remain above health-based
goals, since this aquifer is classified as a potential drinking water
source;
continued monitoring of specified wells; and
- periodic reevaluation of remedial technologies for groundwater
restoration.
The decision to invoke any or all of these measures may be made during a
periodic review of the remedial action, which will occur at intervals of at
least every five years, in accordance with CERCt* 121(e). To ensure state and
public involvement in this decision at this" Site, any changes from the
remediation goals identified in this ROD will be formalized in either an
Zxplanatism of Significant Difference document or an Amendment to this Record
of Decisio*.
Soil Vapor Extraction
A Soil vapor Extraction (SVB) system is an in-situ treatment process used to
120
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MACOH/DOCKERY BOO
clean up soils that contain voc« and SVOCa by inducing a vacuum in the
subsurface soils. The SVE system consists of a network of air withdrawal (or
vacuum) well* installed in the unsaturated zone. A pump and manifold system of
PVC pipes i* used for applying a vacuum on the air withdrawal wells which feed
into an in-line water removal system and an in-line vapor phase carbon
adsorption system for voc and svoc removal. The subsurface vacuum propagates
laterally, causing in-situ volatilization of compounds that are adsorbed to
soils. Vaporized compounds and subsurface air migrate to the air extraction
wells, essentially air stripping the soils in-place.
At the Macon/Dockery site, the vacuum wells can be installed vertically to the
water table at predetermined locations to form the extraction system, vertical
wells were selected due to the depth of the soil strata requiring remediation,
geotechnical conditions, and the depth to groundwater.
on.ce the well systeiferis installed and the vacuum becomes fully established in
the soil column, vocs and some svocs are- drawn out of the soil and through the
vacuum wells. In all SVE operations, the daily removal rates decrease as
contaminants are recovered from the soil. This treatment technology has been
proven effective at treating soils that contain .elevated levels of organic
contaminants.
SVE would be applied to former Lagoon 7 for the removal of tetrachloroethene
(PCS). Based on the VIP modeling, PCS is the only compound in site soils with
the potential to cause ground water to exceed groundwater remediation levels.
Also based on the VIP modeling, target remediation- levels for SVE at the Site
would be 3.0 ppm PCE in the vadose zone beneath former Lagoon 7 (Table 58).
The application of SVE to the unsaturated zone remediation is a multi-step
process, specifically, full-scale vacuum extraction systems are designed with
the aid of laboratory and pilot-scale voc stripping tests. Further testing
will be performed as part of the remedial design.
The final disposition of the spent activated carbon from the in-line carbon
adsorption system will be specified in the remedial.design. The three options
to be considered are. treatment, disposal at an approved hazardous waste
landfill or regeneration of the carbon. Compliance with ARARS for RCRA,
including LORs fpr, treatment, storage, and/or disposal of spent carbon will be
required as part of-ths) XP. .. .
'"-••• . • •-'?!
Bi
Implementation of. the biorenediation phase of this alternative would be
preceded tap a treatability study to determine if the indigenous microbial
population. 4» capable of degrading the PAHs in Lagoon 10. other objectives of
the treatability study would include:
determine the percentage of endogenous microorganisms capable of
degrading PAHs;
determine whether the addition of acclimated microorganisms would be
necessary (bioaugmentation);
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TABU 58
•cure* Remediation Levels for the Macon/DocJcery sit*
Medium
SOIL
SOIL
Chemical
Bens ( a ) anthracene
Benzo(a)pyrene
Benzo ( b ) f luoranthene
Benzo ( k ) f luoranthene
Chryiene
Oibenz ( a , b ) anthracene
Idenopyrene
Tetrachloroethene (PCS)
Remediation
Level
2.0 ppm
(Total)
3.0 ppm
Point of
compliance
Lagoon 10
Lagoon 7
3a«i«
of Goal
Ri«JC
1
1
GK Risk
GW * Groundvattr
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nCOV/DOCXZRT ROD
, - evaluate chemical/physical soil parameters (e.g., pH, moisture
content, nutrient content, dissolved oxygen content, etc.) and
identify optimal conditions for bioremediation; and
determine biodegradation kinetics and project treatment cycles.
A treatability study work plan would be submitted to EPA for approval prior to
implementation.
A treatability study will be conducted during remedial design to determine the
requirements for bioremediation. A remediation level of 2.0 ppm (total
carcinogenic PAHs) for all contaminated soil from Lagoon 10 will be required
prior to replacing any residual material in the final disposal area (Table
58). Final disposal of treatment residuals shall be coordinated with EPA.
Lagoon 10 wastes would be excavated and transferred to a lined waste treatment
cell where bioremediation would be conducted and monitored. The treatment cell
would be enclosed within a greenhouse-type structure that would serve to
maintain optimum microbial growth conditions and to control any air emissions.
vapor phase carbon adsorption would be used, as necessary, to control emission
concentrations from the greenhouse. A 100-foot by 100-foot waste treatment
cell would be lined with a 60 mil-HOPE liner to provide containment of the
wastes. A 6-inch layer of sand and/or gravel would be placed within the cell
to provide a drainage layer for excess moisture. The waste treatment cell
would be built on a slight incline so that excess moisture would gravity drain
to a sump at the low end of the cell. This water would be reapplied to the
wastes during the next application of nutrients. Fertilizer in the box trailer
at the Upper Macon site would be evaluated as a potential source of nutrients.
Excess water not recycled would be treated in the ground water treatment
system, or disposed otherwise depending on any treatment requirements.
Applying a 6 to 8 inch layer of lagoon soils above the drainage layer would
accommodate approximately 200 cubic yards. Actual treatment design and
operation would be established during Remedial Design.
A significant reduction in PAH concentrations would be expected within 100 days
after treatment begins based on remediation at other sites. The wastes would
be sampled for volatile and semi-volatile analysis just prior to treatment and
100 days into treatment to determine whether target remediation levels have
been achieved. Periodic maintenance requirements would include tilling,
watering, and fertilisation of the wastes. Details of treatment cell
construction and operation would be prepared during Remedial Design.
Treated v**t«s would be returned to Lagoon 10 upon reaching the targeted
remediatioft level. The treatment residuals would be covered with a low
permeability cap. The existing clay at Lagoon 10 would be replaced and
recompacted to fora the cap. The treatment cells would be dismantled and
disposed as non-hazardous waste. Actual closure requirements would be
established during Remedial Design.
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mediation would involve transferring all vessel contents into secure
transportation vehicles and dismantling the vessels, some or all of the
building* Bay need to be demolished and removed during remediation of the
site. Also, if evidence of leakage ia noted after the vessels are removed, the
remedial action will include cleanup of any soils which have become
contaminated as a result of the leak. Hazardous vessel contents would be taken
to a RCRA-approved facility for disposal. Non-hazardous vessel contents and
the vessel pieces would be recycled or sent to an industrial landfill for
disposal.
Hazardous solids would be drummed and taken to a RCRA-approved landfill for
disposal while the remaining solids (including tar) would be disposed as
non-hazardous waste. Hater would be sent through the ground water treatment
system, or taken to the local Publicly owned Treatment Works for disposal,
pending comparison with pretreataent requirements, oil would be pumped into
tanker truck* for offsite reclamation or incineration, ultimate disposition of
the oils would be based on the bulk concentrations in the tanker that would be
sent to the receiving facility.
Fertilizer in the box trailer and the boiler insulation would be disposed of as
non-hazardous waste or recycled. Boiler insulation has not been characterized
but, based on the assumed age of construction, may contain asbestos.
Characterization of the insulation would be required prior to dismantling the
boiler. To be conservative, it is assumed that disposal of boiler insulation
would have to comply with asbestos handling requirements.
Actual requirement* for vessel remediation would be established during Remedial
Design.
d.
An ecological endangerment assessment conducted for the site identified areas
of possible concern which require further characterization during the Remedial
Design. The following work is required to address the ecological effects of
the contaminated surface water, sediments, and soilst
conduct chronic aquatic toxicity test* for location* where the
toxicity quotient exceed* one;
eolleot representative biota (upper carnivore fish species,
invertebrate species;
conduct sedijnent toxicity tests for those locations where the
toxicity quotient exceed one;
evaluate the potential environmental effects of the contaminated
soil, using soil toxicity testing, elutriate testing, or other
appropriate method*.
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ROD
Actual stapling and monitoring requirements vill be established during Remedial
Design. If the result* of this additional tasting identify additional areas of
concern, the scope of remediation will not be limited by this ROD.
e. COST
The total present worth cost for the selected alternative is $8,700,000. The
break down of this cost is specified below.
The present worth cost for the groundwater extraction (40 gpm), air stripping,
coagulation/filtration and infiltration gallery is approximately $6,900,000.
This cost includes a capital cost of $1,700,000 for construction of the
groundwater extraction system, the treatment unit, treated groundwater
discharge system, and all associated piping. This cost also includes
expenditures for operation and maintenance of the system of $5,200,000 for 30
years.
The present worth cost for the soil Vapor Extraction at former lagoon 7 and
land treatment at lagoon 10 is approximately $1,500,000. This cost includes a
capital cost of $1,300,000 for installation of the materials for the
bioremediation treatment cell, SVE extraction wells, manifold piping, and
potentially a clay cap for lagoon 10 residuals. This cost also includes
expenditures for operation and maintenance of the system of $200,000 for 30
years; SVE - l year.
The present worth cost for the off-site disposal of vessels is approximately
$300,000. This cost includes a capital cost of $300,000 for vessel demolition
& waste disposal, fertilizer removal, trailer disposal and boiler removal &
disposal. This cost includes no annual expenditures for operation and
maintenance $0.00.
Capital Cost for Groundwater Extraction and Treatment System $1,700,000.00
Operation t Maintenance Costs for 30 years $5,200,000.00
Capital cost for the SVE system and Land Treatment $1,300,000.00
operation * Maintenance costs for 30 years; SVB - 1 year $ 200,000.00
Capital Cost for Off-site disposal of vessels $ 300,000.00
operation < Maintenance Costs for disposal of vessels $ 0.00
TOTAL PRESENT WORTH COST $8,700,000.00
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11..
Under its legal authorities, EPA'a primary responsibility at Superfund sites is
to undertake remedial actions that achieve adequate protection of human health
and the environment. Zn addition, Section 121 of CERCLA, 42 u.s.c. S 9621,
establishes several other statutory requirements and preferences. These
specify that when complete, the selected remedial action for this site must
comply with applicable or relevant and appropriate environmental standards
established under Federal and state environmental laws unless a statutory
waiver is justified. The selected remedy also must be cost-effective and
utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Finally, the statute
includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous wastes as
their principal element. The following sections discuss how the selected
remedy meets these statutory requirements.
The selected remedy will permanently treat the groundwater and soil and removes
or minimizes the potential risk associated with the wastes. Dermal, ingestion,
and inhalation contact with Site contaminants would be eliminated, and risks
posed by continued groundwater contamination would be reduced.
b. COMPTiTIUTR WITH *»**•
The selected remedy will comply with all Federal- and state applicable or
relevant and appropriate chemical-, location-, and action-specific requirements
(ARARs). compliance with ARARs for each of the components of the selected
remedy is discussed below.
GWC-2As Recovery cad Treatment of all site Groundvater e-rreertlng Groundwater
using Air stripping, coagulation/filtration
Groundwater remediation levels (Table 57) would be met at the site under this
alternative. Discharge of ground water to Solomons creek would satisfy AHQC.
This alternative therefore complies with ARARS.
off-sit* discharge of treated groundwater to a surface water (Solomons creek)
would h*f» to comply with the requirements of an NPDES permit. Discharge to an
inf iltrafetcm gsAlery would have to comply with the requirements of a
Hon-Diseasar^e '•rait. Air stripper emissions would comply with North Carolina
allowable) ambient levels. Substantive requirements would be established during
Remedial Design.
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SC-41
SOU
10
extrmotion (SVB) for Lagoon 7, bioreaediitinn for Lagoon
Operation of the SVE system would conform to North Carolina air emission
requirements (15 NCAC 2D.1104). The remadial baaltb and aafaty plan would
conform to 29 CFR 1910.120.
There ara no ARARa govarning aubaurface soils at tha sita. AM discussed, RCRA
LOR ara not ARAR for land traatmant of Lagoon 10 materials. Bioramediation
oparationa would conform to North Carolina air emission requirements, as
nacaaaary.
V-2:
Off-ait* disposal
RCRA ragulationa wara idantifiad aa potentially relevant and appropriate ARARa
for vessel remediation. RCRA disposal guidance was identified as an
action-specific ARAR while RCRA hazard characteristics were identified aa a
chemical-specific ARAR (i.e., TCLP). Alternative V-2 would follow appropriate
RCRA requirements and would therefore comply with these potential ARARa.
If the industrial boiler (Building 2, Figure 1) contains friable asbestos,
three potential action-specific ARARa may apply for offsite disposal: (1) 29
CFR parts 1910.1001 and 1926.58 (general asbestos regulations under the
Occupational safety and Health Administration (OSHA) and
construction/demolition regulations, respectively)r (2) North Carolina
specifications for Asbestos Abatement (Division of.state Construction,
Department of Administration, as amended in February 1988) and (3) 40 CFR Part
61 (CAA) EPA National Emission Standards for Hazardous Air Pollutants
(NESHAP). Most of these regulations pertain to the packing and shipping of
asbestos-containing materials such that the amount of asbestos fibers entering
the air and affecting potential human exposure ara minimized. Alternative v-2
would follow the OSHA, North Carolina and EPA requirements and therefore would
comply with these potential ARARS.
The selected groundwater and source remediation technologies are more
cost-effective than the other acceptable alternatives considered primarily
because they provide greater benefit for the cost since they provide for
treatment of the waste.
The selected remedy represents the maximum extent to which permanent solutions
and treatment can be practicably utilized for this action, of the alternatives
that are protective of human health and the environment and comply with ARARS,
EPA and the state have determined that the selected remedy provides the bast
balance of trade-offs in terms of long-term effectiveness and permanence;
reduction in toxicity, mobility or volume achieved through treatment;
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. EBs«^ -.
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